What is Ongoing Due Diligence (ODD)?
Last updated: 23 October 2026
What is Ongoing Due Diligence?
Ongoing due diligence (ODD) is the continuous analysis of customers so that banks and financial institutions can understand the customer relationship, the customer’s transactions and the nature of their business. Its purpose is to identify, mitigate and manage money laundering and terrorist financing risk after a customer has been onboarded. ODD also confirms that a customer’s risk profile, business activity and source of funds remain in line with the institution’s risk appetite. It is a key part of effective KYC procedures and compliance obligations. See customer due diligence (CDD) for the checks carried out at onboarding.
Why is ongoing due diligence required?
A customer who looked low risk at onboarding can change. Their ownership, business, geography or behavior may shift, and their status may change, for example if they become a PEP. FATF standards require firms to monitor business relationships on an ongoing basis, scrutinize transactions against what they know about the customer and keep customer information up to date, and national laws build this into AML program requirements.
What does ongoing due diligence involve?
- Reviewing and refreshing customer information and documents
- Re-screening against sanctions, PEP and adverse media sources
- Monitoring activity through transaction monitoring
- Reassessing the customer risk rating
- Updating source of funds and, for higher-risk customers, source of wealth
- Applying enhanced due diligence where risk has increased
- Escalating concerns and, where needed, filing a suspicious activity report or exiting the relationship
What triggers an ongoing due diligence review?
Reviews happen in two ways. Periodic reviews follow a schedule set by risk, with higher-risk customers reviewed more often. Event-driven reviews respond to something changing, such as:
- A change in ownership, control or business activity
- Unusual activity flagged by monitoring
- New adverse media or a sanctions or PEP match
- Expired identity documents or missing information
- A new product or service request, or a dormant account becoming active
- A change in the regulatory or risk environment
How is ongoing due diligence changing?
Perpetual KYC (pKYC) moves ODD from fixed cycles to continuous updating, in line with the idea of continuous compliance. SymphonyAI calls this approach Always-on Compliance™, where risk intelligence is applied continuously instead of waiting for a scheduled review.
What are the challenges?
- Backlogs of periodic reviews that tie up analysts
- Customer outreach that creates friction and delays
- Data held in separate systems, which hides changes
- Inconsistent triggers and rules between teams
- Limited evidence of why a review was or wasn’t done, which creates audit risk
How does AI support ongoing due diligence?
AI can monitor customers and external sources continuously, detect changes that matter and refresh risk ratings, so analysts spend time on genuine changes instead of routine reviews. Agentic AI can assemble the evidence for a review and recommend an outcome for a human to approve, with a full audit trail. See how SymphonyAI KYC and CDD software and Always-on Compliance™ support this.
FAQs
What is the difference between CDD and ongoing due diligence?
CDD establishes who a customer is and assesses their risk at onboarding. Ongoing due diligence keeps that understanding current for as long as the relationship lasts.
How often should ongoing due diligence be performed?
At a frequency set by the customer’s risk, and whenever a material event occurs. Many firms review higher-risk customers more often and lower-risk customers less often.
Is ongoing due diligence the same as transaction monitoring?
No. Transaction monitoring is one part of it. ODD also covers refreshing customer information, re-screening and reassessing risk.
What is the difference between ODD and perpetual KYC?
ODD is the obligation to keep customer information current. pKYC is a continuous, largely automated way of meeting it.
For more, see anti-money laundering (AML).